The Multi-Sector Air Pollutants Regulations (the MSAPR) was registered by Environment and Climate Change Canada (ECCC) in June 2016 with the objective to achieve consistent Canada-wide performance standards for certain industrial facilities and equipment. Stationary spark ignition engines are targeted under Part 2 of the MSAPR. MSAPR establishes a process for registering, monitoring, testing and reporting of oxides of nitrogen (NOx) emissions and provides NOx emission intensity limits (g NOx / kWh) which are phased in over time.
Part 2 applies to stationary spark ignition engines that meet the definition in the MSAPR, that are “pre-existing” (i.e. manufactured, owned or operated before September 2016), are at an “oil and gas facility” (other than an asphalt refinery) as defined, are ≥ 250 kilowatt (kW) rated output capacity (break power) and that combust gaseous fossil fuel. Part 2 also applies to stationary spark ignition engines that are “modern” (meaning they are not “pre-existing”), are at one (1) of thirteen (13) regulated facilities as defined, are ≥ 75 kW (for an engine deemed “Regular” use) or ≥ 100 kW (for an engine deemed “Low” use) and that combust gaseous fossil fuel.
Engines that are operated at least one (1) hour per year are considered “Regular” use unless specifically deemed to be “Low” use. One of the eligibility criteria for the election of an engine as "Low” use is if it is operated ≤ 1314 hrs in a 3 consecutive year period (i.e. ≤ 5% of the time).
Part 2 sets out nitrogen oxides (NOx) emission intensity limits (g NOx/kWh) as well as compliance testing, operation and maintenance and reporting requirements.
Important recent and upcoming deadlines are:
- ECCC hosted training sessions on Part 2 and the Online Reporting Tool on May 23, 2018 (Gatineau: in person or webinar) and June 5 to 7, 2018 (Calgary: in person)
- Requirements for “modern” engines are in force now including the NOx emission intensity limit (2.7 g NOx/kWh) which applies to ≥ 75kW and “Regular” use and ≥ 100 kW and “Low” use
- The deadline to register and report on “modern” engines that were operational in 2017 is July 1st, 2018
- “pre-existing” engines ≥ 250 kW (“Regular” and “Low” use) are to be registered by January 1, 2019 (or July 1 that follows the year in which there was a change in the “responsible person” or change in the engine)
- “pre-existing” and “Regular” use engines, the first phase NOx emission intensity limit applies January 1, 2021 and the second phase limit applies January 1, 2026 (Note: there are no limits for “pre-existing” and “Low” use engines under MSAPR)
Other factors to consider with associated reporting deadlines include:
- submission of Notice of Election to have engine deemed “Low” use
- submission of Notice of Election for use of Yearly Average Approach (also referred to as Fleet Average Approach) for “pre-existing” engines
At the time the NOx emission intensity limits apply, compliance must be demonstrated by conducting an initial performance test and reporting with the frequency of ongoing performance tests or simplified emission checks impacted by whether the engine is “Regular or “Low” use, the output capacity and the type of engine (i.e. rich burn versus lean burn).
Next Steps on the Path to Compliance:
The lower NOx emission intensity limit would apply as early as 2021 for impacted “pre-existing” engines. Projects to lower the NOx emission intensity can be capital intensive and time-consuming so forward planning is highly recommended. Suggested next steps in the development of a compliance strategy should consider:
- A detailed analysis of facilities to confirm “pre-existing” engines are indeed subject to MSAPR Part 2 considering historical and expected future time of use as well as availability/suitability of site conditions for future performance testing;
- A detailed analysis of timelines and mitigation or other measures required to ensure compliance including possible implications of choosing the Flat Limit Approach versus the Yearly Average Approach for your fleet of “pre-existing” engines (Note: “modern” engines are subject to the Flat Limit Approach only);
- Baseline emission testing, although not specifically required in advance of registering your “pre-existing” engines, to confirm the NOx emission intensity as opposed to estimates (Note: especially important if mitigation may be required to meet the future limits); and
- An assessment of opportunities for synergies or efficiencies of the activities required in support of the MSAPR and other compliance activities such as those required in support of a provincial environmental permit or other policies such as those related to the use of an emergency generator (engine) in non-emergency situations.
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